Policies and Procedures

Business Ethics and Conduct Policy

We will at all times operate our business in full compliance with the law and in accordance with the highest principles of honesty and ethical conduct. Our Business Ethics and Conduct Policy guides us on engaging fairly with the Company’s customers, suppliers, competitors and employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.

Electronic Information Systems Policy

We are committed to the protection of data, including that of the Company, our employees, our customers and stakeholders. Our Electronic Information Systems Policy applies to all our employees and their use of electronic resources. We recognize our duty to protect data that is gathered or stored through our voicemail system, email system, internal computer networks and through Internet access. Employees are guided in the use of these systems and prohibitions on the use of these systems for personal purposes are provided, along with restrictions on the purchase and installation of hardware and software.

Employee Handbook

Our record of success reflects the high standards of performance our employees bring to their jobs. Our employees’ contributions are the keys to our achievements as a company and we encourage work to be both satisfying and challenging. The Employee Handbook highlights important Company policies and benefits, including information on diversity and equal opportunity, employee health and well-being, labor-management relationships, employee performance and career development and worker rights.

Environmental, Social, and Governance (ESG) Policy

We are committed to incorporating ESG standards into our business practices. ELS’ commitment to sustainability embraces a holistic ESG approach which supports our business model, minimizes our environmental impact, maintains a safe and healthy workplace and upholds the high standard of business ethics and conduct we are proud of.

Guidelines on Corporate Governance

How we conduct ourselves begins with our tone at the top. Our Guidelines on Corporate Governance, along with the charters and key practices of the Board’s committees, reflect the Board’s commitment to monitor the effectiveness of policy and decision-making at both the Board and management levels. The Board’s role is to oversee management in conducting the business and affairs of the Company competently by exercising good business judgment.

Human Rights and Labor Rights Statement

We are committed to the protection and advancement of human rights and to ensuring that our operations in all our regions function with integrity. Our Human Rights and Labor Rights Statement confirms our policies on the topics of Fair Labor Practices, Child Labor, Forced Labor and Human Trafficking, Health and Safety, Diversity and Inclusion and Ethical Conduct.

Policy on Securities Trading

Our employees and Board members are subject to certain legal restrictions regarding the purchase and sale transactions involving ELS securities. ELS is committed to full compliance with these legal restrictions and has developed certain policies and procedures necessary to implement and assure compliance, as included in our Policy on Securities Trading.

Political Contributions Policy

Political contributions include any gifts, loans, or deposits of money or anything of value in connection with any election campaign, for the payment of debt incurred in connection with any election campaign or for transition or inaugural expenses of the successful candidate. Political spending is not a core part of our Company strategy and all political contributions require the approval of our CEO.

Safety Handbook

A safe and healthy working environment is everyone’s concern. We empower all employees to ensure our place of employment is reasonably free from hazards which may cause illness, injury, or death. We maintain an effective and continuous safety program, incorporating educational and monitoring procedures designed to teach safety, to correct deficiencies and to provide a safe work environment.

Our Safety Handbook provides basic information on applicable OSHA regulations and training topics that may be encountered in the regular operation of our properties, which we couple with in-person and online training to ensure our purpose of safety compliance is met.

Reporting a Concern

Our Nature is to treat all employees fairly and considerately and to ensure that each employee has the right to communicate requests, complaints, problems and suggestions to management regarding his or her well-being at work.

To help employees report potential misconduct, the Company provides several reporting channels, including managers, members of our People and Culture department, the Legal department and Internal Audit department.

In addition, the Company has established a confidential Alertline for reporting Ethics and Compliance concerns. Our Audit Committee Chairperson and the ELS Compliance Officer, who is independent of management and reports to the Board, are responsible for receiving and handling concerns that are reported through the Alertline. The Company has established a confidential hotline for all employees to report workplace health and safety concerns. Our Risk Management department is responsible for receiving and handling concerns that are reported through the safety hotline. The multi-lingual Alertline and the safety hotline are staffed 24 hours a day, 7 days a week by an independent third party and complaints may be made anonymously. The Company will not tolerate retaliation against an employee or stakeholder who reports misconduct in good faith.

Cybersecurity

At ELS, we rely extensively on internally and externally hosted computer systems to process transactions and manage our business.

These systems and websites are subject to system security risks, cybersecurity breaches, outages and other risks.

We employ a number of measures to prevent, detect and mitigate these threats. ELS has a dedicated Security and Compliance team to focus on the areas of Risk Management, Network Hardening and Data Protection. The team provides regular reports and updates to the Audit Committee of our Board of Directors, which has oversight to any information technology or cyber technology risks relating to the Company. We have monthly internal cybersecurity newsletters, monthly phishing campaigns and are implementing a real-time risk assessment process. Additionally, all ELS team members are required to participate in cybersecurity and data protection training.